Medical food (MF) is not new, but because medical food products have been predominantly used in hospitals and other institutional care settings, many physicians have a limited understanding of these products. As created by the Orphan Drug Act Amendments of 1988 the FDA category "Medical food" is defined, at 21 U.S.C. ¤360ee (b)(3) as "a food - which is formulated to be consumed or administered enterally - under the supervision of a physician - and which is intended - for the specific management of a disease or condition - for which distinctive nutritional requirements - based on scientific principles - are established by medical evaluation."
Limbrel is a prescription medical food product for the daily nutritional management of the metabolic aspects of osteoarthritis. Limbrel is not a drug, nor a dietary supplement. Because Limbrel is a Medical Food (MF) product, we are required to describe it differently from how a drug or dietary supplement is described.
By statutory and regulatory definition, product claims must be explicitly different for medical food products versus drugs versus dietary supplements. Generally, Medical Food claims reference the "dietary management" or "distinctive nutritional requirements" of a particular disease or the metabolic processes of that disease, whereas drug claims reference "curing, treating, preventing or mitigating" the effects or symptoms of a particular disease, while dietary supplement claims reference "supporting" healthy function of the body or particular body organ or system. First, osteoarthritis patients are shown to have distinctive nutritional requirements and metabolic imbalances. Then, for example, a Medical Food may claim the dietary management of metabolic processes of osteoarthritis, whereas a drug may claim the reduction of osteoarthritis pain, while a dietary supplement may claim the support of overall health of joints. A Medical Food must meet the distinctive nutritional requirements of a disease through dietary management, whereas a drug may address the symptoms of a disease or its treatment or prevention of the disease.
Claims for both MFs and drugs must be supported by solid laboratory and clinical data. But, by contrast, for a drug, the safety of the product and both the therapeutic claims and the ingredients must be pre-approved by the FDA through extensive clinical testing. MFs have up-front safety obtained through GRAS (Generally Recognized As Safe) status of the ingredients, including use of the food or food additive or component in perhaps millions of people, whereas drugs have unproven safety that must first be shown in animals and then be tested in human clinical trials, which typically exclude wider populations with various health problems. Medical Food ingredients have GRAS designation, the highest FDA standard of safety given to food. Most MFs are also tested in clinical trials to confirm their "traditional use" safety.
The use of Medical Food, regulated by the FDA, represents an entirely different approach to managing diseases. For example, unlike drugs, Limbrel does not treat or mask the symptoms of osteoarthritis. Instead, Limbrel manages the underlying metabolic processes of osteoarthritis to restore the proper metabolic balance of inflammatory metabolites at the cellular level, and thereby promotes normal physiologic function.